HomeMy WebLinkAbout05-28-14 (2) C7 O
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In re Estate of Frank E. Byers, : IN THE COURT OF COMMON PL
F I ,' �", cam,
deceased : CUMBERLAND COUNTY, PENN_V' Zt3NIAc v.
: BEFORE THE REGISTER OF WIL?3 CO i7
:NO. 21-2014-0438
o r
MOTION o
AND NOW COMES Petitioner, Sylvia A. Waters, an intestate heir of Frank E.
Byers, deceased, by and through her attorney, James D. Cameron, and respectfully
represents as follows:
1. On May 6, 2014, Petitioner filed a Petition for Citation with the Register of
Wills, seeking her appointment as Administratrix, C.TA., of the Estate of Frank E. Byers.
2. On May 7,2014,the Register issued and served a Citation, directed to Paul E.
Waters,Jr., Maxine B. Patterson, Charmaine N. Felton, Candace J. Hodge, Moni L.
Harper, Shanell Budd, and Heather Charles.
3. As of the date of the filing of this Motion, no oppositional responses to the
Citation have been filed with the Register.
4. Petitioner has received properly-executed Renunciations from three of the
intestate heirs—Moni L. Harper, Shanell Budd, and Heather Charles. These
Renunciations are attached hereto, identified as "Exhibit A".
5. Petitioner has received signed Renunciations (but not notarized nor
executed before the Register) from the three remaining intestate heirs--Maxine B.
Patterson, Charmaine N. Felton, and Candace J. Hodge, These Renunciations are
attached hereto, identified as `Exhibit B".
6. As demonstrated by Exhibits A and B, evidence exists that all of the intestate
heirs of Frank E. Byers consent to the appointment of Sylvia A. Waters as
Administratrix, C.TA., of the Estate of Frank E. Byers.
7. Paul E. Waters, Jr., the named Executor in the Will, has failed to respond to
the Citation.
8. Petitioner is submitting her Petition for Probate, the Last Will and Testament
of Frank E. Byers, dated August 18, 1983, and an original death certificate,
contemporaneously with the filing hereof.
WHEREFORE, Petitioner respectfully requests the Register to issue to grant the
relief requested in the Petition for Citation; admit the Last Will and Testament of Frank
E. Byers to probate; and issue Letters of Administration, C.TA., in the Estate of Frank E.
Byers to Sylvia A. Waters, pursuant to 20 Pa.C.S. §3155(b)(3).
Respectfully Submitted,
J e . Cameron
Attorney I.D. No. 58998
1325 North Front Street
Harrisburg, PA 17102
(717) 236-3755
Attorney for Petitioner,
Sylvia A. Waters
CERTIFICATE OF SERVICE
I, JAMES D. CAMERON, Attorney for Petitioner, Sylvia A. Waters, hereby
certify that I have served a true and correct copy of the foregoing Motion by first class
mail,postage pre-paid, this 28`x' day of May, 2014, addressed as follows:
Paul E. Waters, Jr.
1447 Barnhardt Lane
Rahway,NJ 07065
Maxine B.Patterson
345 B Street
Carlisle,PA 17013
Charmaine N. Felton
349 B Street
Carlisle, PA 17013
Candace J. Hodge
351 B Street
Carlisle,PA 17013
Muni L. Harper
506 Cherry Street
Carlisle, PA 17013
Shanell Budd
636 Hamilton Street
Harrisburg, PA 17102
Heather Charles
109 Minick Drive
Newberg, PA 17240
J e D. eron
A ney I.D. No. 58998
1325 North Front Street
Harrisburg, PA 17102
(717) 236-3755
Attorney for Petitioner,
Sylvia A. Waters
RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Frank E. Byers
, Deceased
I, Moni L. Harper in my capacity/relationship as
(Print Name)
child and intestate heir of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Sylvia A. Waters (pursuant to 20 Pa.C.S. 3155(b)(3))
(Date) (Signature)
506 Cherry Street
(StreetAddress)
Carlisle, PA 17013
(City,State,Zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this I Tli _d y party executing this renunciation and certified
of 1 �l that he or she executed the renunciation for the
purposes stated within on this day
of
Deputy for Regtsi r of Wills Notary Public
My Commission Expires:
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's Commission.)
Form RW-06 rev. 10.13.06
RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Frank E. Byers
Deceased
I, Shanell Budd in my capacity/relationship as
(Print Name)
child of Linda Boswell (deceased) and intestate heir of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Sylvia A. Waters (pursuant to 20 Pa.C.S. 3155(6)(3))
xd- 7/,wl� 41,v
(Date) (i tire) .
1 836 Hamilton Street
(Street Address)
Harrisburg, PA 17102
(City,State,Zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day party executing this renunciation and certified
of that he or she executed the renunciation for the
purposes stated within on this /9-/'4 day
ofo/S/
Deputy for Register of Wills Notary Public
My Commission Expires: 11.)-71X018
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's Commission.)
f PENNSYU0MIA CaON0 oSNELLAL EAL
Farm RW-06 rev. 10.13.06 LYDIA R DAVIS
Notary PUNIC
Er msWAT ARA TWP,DAUPHIN COUNTY
Conlrebstan Expires Jan 27,2015
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RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Frank E. Byers Deceased
I, Heather Charles in my capacity/relationship as
(Print Name)
child of Linda Boswell (deceased) and intestate heir of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Sylvia A. Waters (pursuant to 20 Pa.C.S. 3155(b)(3))
20i �
(Dale a (Signature)
109 Minick Drive
(Street Address)
Newberg, PA 17240
(City,State.Zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day party executing this renunciation and certified
of that he or she executed the renunciation for the
purposes stated within on this q
of
Deputy for Register of Wills Notary Public
My Commission Expires: nO il, JV1 aD/7
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's Commission.)
L H OF
PENNSYLVANIA
NOTARIAL SEAL
DEBORAH WARREN,potgM Public
Form RW--06 rev. 10.13.06 Som of Shippensburp,Cumberland Cwmb
my CommWon E)Ores November a,2017
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RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Frank E. Byers
Deceased
1, Maxine B Patterson in my capacity/relationship as
(Print Name)
child and intestate heir of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Sylvia A. Waters (pursuant to 20 Pa.C.S. 3155(b)(3))
l /' 11 Grn� 6
(Dole) �aYr
(Signature)
345 B Street
(Street Address)
Carlisle,PA 17013
(City,sane,zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day party executing this renunciation and certified
of that he or she executed the renunciation for the
purposes stated within on this day
of
Deputy for Register of Wills Notary Public
My Commission Expires:
(Signature and Seat of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's Commission.)
Farm RW-06 rev. !0.73.06
RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY, PENNSYLVANIA
Estate of Frank E. Byers
Deceased
I, Charmaine N. Felton
child and intestate heir
(PrmtNante) , in my capacity/relationship as
of the above Decedent, hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Sylvia A. Waters (pursuant to 20 Pa.C.S. 3155(b)(3))
(Date)
(Signature)
349 B Street
(Street Address)
Carlisle,PA 17013
(City,State,Zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day
of party executing this renunciation and certified
that he or she executed the renunciation for the
Purposes stated within on this day
of
Deputy for Register of Wills
Notary Public
My Commission Expires:
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's commission.)
Form RW-O6 rev.10.13.06
RENUNCIATION
REGISTER OF WILLS
CUMBERLAND COUNTY,PENNSYLVANIA
Estate of Prank E. Byers Deceased
I, Candace J. Hodge in my capacity/relationship as
(Print Name)
child and intestate heir of the above Decedent,hereby renounce the right to
administer the Estate of the Decedent and respectfully request that Letters be issued to
Sylvia A.Waters (pursuant to 20 Pa.C.S. 3155(b)(3))
t
(Date) (Sig-u—)
351 B Street
(StreetAddress)
Carlisle,PA 17013
(City,State.Zip)
Executed in Register's Office Executed out of Register's Office
Sworn to or affirmed and subscribed Before the undersigned personally appeared the
before me this day party executing this renunciation and certified
of that he or she executed the renunciation for the
purposes stated within on this day
of
Deputy for Register of Wills Notary Public
My Commission Expires:
(Signature and Seal of Notary or other official qualified to
administer oaths. Show date of expiration of Notary's Commission)
Foe in RW-06 rev.10.13.06